1. INTRODUCTION

The right to privacy and, specifically, the right to personal data protection is one of the core values of FLUIDRA S.A., the parent company of the Fluidra Group (hereinafter, FLUIDRA), as is set out in our Code of Ethics.

The aim of this policy is to explain how FLUIDRA shall process the personal data it collects from the various forms posted on its Website at www.blueriiot.com/eu-es.com. Your personal data shall be processed in the strictest confidence and solely for the purposes to which you have consented, as explained below in this General Privacy Policy and in the Basic Privacy Disclosures on each of the forms.

2. Commitment to privacy

FLUIDRA is fully committed to compliance with the European Union’s General Data Protection Regulation and the laws on personal data protection in force at any given time, which is a top priority for FLUIDRA.

Therefore, FLUIDRA has made the decision to implement the following principles, with privacy forming the basis of all data processing.

Transparency in data processing is one of our priorities, so whenever we collect personal data about you we shall duly inform you of the purpose for which they shall be processed in the relevant privacy policy.

We shall only process the data that are strictly necessary for the purposes about which you shall have been informed.

We shall never oblige you to provide personal data, unless absolutely necessary to render you a service that you may have requested.

Whenever possible, we shall make the most straightforward means available to you for you to control your personal data.

Your data shall not be assigned, sold, leased or otherwise made available to third parties, except in the case of FLUIDRA’s service providers that render certain services to FLUIDRA, which shall under no circumstances process them for their own purposes. Some of these service providers may be based outside of the European Union, as stated in the “International Transfers” section.

PURPOSE OF DATA PROCESSING:

FLUIDRA collects your personal data to process your requests and to provide you with the products and services that may be of interest to you. Depending on your interaction on any given website, we may process your data for the following reasons, among others:

• To be able to send you a newsletter adapted to your interests.

• To contact you in order to respond to your questions and concerns.

• To improve our websites, services and products, as well as to provide a better service and content.

It may occasionally be necessary to process your personal data to comply with legal obligations, or in relation to a contractual relationship we may have with you.

In all other cases, whenever required, we shall ask you for your consent for processing

your personal data.

3. Marketing messages

Within the framework of its marketing activities, FLUIDRA may provide you with the means to register or subscribe to the company's newsletters and marketing information. The sending of such messages is subject to your consent at all times.

If you give your consent, FLUIDRA shall send you customized information about our products, business and services in accordance with your tastes and preferences.

You may withdraw your consent at any time whenever you receive marketing messages through the link or button enabled for this purpose in all messages, or by expressing your desire to withdraw your consent by sending an email to dataprivacy@fluidra.com.

4. Automated decisions and the creation of profiles

For some services, we may process your personal data using automated means. This means that certain decisions are automatically taken without human intervention, such as handling replies to your comments and inquiries on the live chat service.

Your data may likewise be processed to create a profile for the purpose of predicting your behavior on the Website by displaying the main page of products that may be of interest to you, based on the preferences you have shown from your browsing habits or on information obtained from cookies. You may contact us by email at dataprivacy@fluidra.com.

5. Term of data processing and storage

FLUIDRA is committed to only processing your personal information when we actually need to do so in order to provide you with quality service. Therefore, we make every reasonable endeavor to keep the term of processing and storage of personal data as short as possible.

To this regard, we shall inform you of the term of processing and/or storage of personal data on each form from which data are collected.

In any event, even if you request that we delete your data, we may store and keep them on record, subject to their being blocked as required by law, for the term required for us to fulfill our legal obligations and for their disclosure to the competent Authorities of the various matters to which they are subject.

6. International transfers

FLUIDRA, as an international company, has international service providers that may render their services from outside the EU. As a result, it is possible that your data may be transferred outside of the European Union or the European Economic Area.

In any event, FLUIDRA shall ensure that such data processing is protected by the appropriate safeguards, which may include Standard Clauses approved by the EU that are taken from agreements approved by the EU regulator and that provide sufficient safeguards to ensure that data processing complies with the requirements of the EU’s General Data Protection Regulation, as well as third-party certifications, amongst others.

7. Exercise of rights and complaints to the Spanish Data Protection Agency (AEPD)

As a result of FLUIDRA processing your personal data, current laws grant you a number of rights. Below is a brief explanation of each right to assist you should you wish to exercise them:

• Right of access. You are entitled to find out which of your personal data are being processed and the reasons for doing so.

• Right to rectification. Your data belong to you and, as such, you may request that they be rectified at any time if our records are inaccurate.

• Right to erasure. You may at any time request that your personal data be erased from our records. However, as set out in the above section on data storage, it should be remembered that in certain circumstances compliance with the laws in force may prevent this right from actually being exercised.

• Right to object. You may object to your personal data from being processed in relation to any of the purposes for which we process them, pursuant to the privacy policies that may apply in each case.

• Right to restriction of processing. You may request restriction of processing in the following cases:

If you consider that the personal data in our database are incorrect or inaccurate.

If, in the event that you believe we are not legitimately processing your data, you prefer that we restrict processing rather than erasing the data.

If the data we have on file are no longer required for the purposes we collected them for, but you need us to store them to file a legal claim.

If, having exercised your right to object to the processing of your data for a specific purpose, you are awaiting a reply from us to this regard.

• Right to data portability. Provided that it is technically possible and reasonable to do so, you may request that the personal data you have directly submitted to us be disclosed to another data controller. If this is possible, we shall directly provide your data to the other data controller; if this is not possible we shall provide the data to you in a standard format.

You may revoke your consent for us to process your data at any time, in which case the only consequences for you, depending on which right you have exercised, shall be our inability to provide you with certain services.

You may exercise your rights by sending an email to FLUIDRA at dataprivacy@fluidra.com, in which case you must enclose a copy of a valid ID document.

In addition, should you wish to do so you may contact our Data Protection Officer at dataprivacy@fluidra.com.

In the event that you did not wish to exercise a specific right but needed to make an inquiry or suggestion related the processing of your personal data, you may also write to the addresses provided for exercising your rights.

Should you not receive a reply within a reasonable amount of time, namely, 2 months, you may lodge a claim with the Spanish Data Protection Agency.

In Spain, the Competent Authority is the Spanish Data Protection Agency.

8. Confidentiality and security in data processing

Your personal data are very important to us and we undertake to process them in the strictest confidence and with utmost discretion, as well as to implement all security measures that we consider are required and reasonable.

In this regard, FLUIDRA hereby represents and warrants that it has implemented all available technical means to prevent the loss, misuse, alteration, unauthorized access and theft of the data provided by users.

9. Social media

Social media are part of the everyday lives of many Internet users, so FLUIDRA has created a number of profiles on social media platforms.

All users may join the pages or groups set up by FLUIDRA on the various social media platforms.

However, you are reminded that, unless we directly ask you for your data (for example, through marketing campaigns, competitions, promotions or in any other valid way), your personal data belong to the corresponding social media platform. Therefore, we recommend that you read the terms and conditions of use and privacy policies carefully and be sure to set your preferences insofar as the processing of your data is concerned.